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October 10, 2018

The U.S. "prudential regulators" final rule on uncleared swap margin requirements was published in the Federal Register. The final rule, issued by the Federal Reserve Board, the Office of the Comptroller of the Currency, the FDIC, the Farm Credit Administration and the Federal Housing Finance Agency, will become effective on November 9, 2018. As previously covered, legacy swaps that have not been subject to margin requirements will not become subject to margin requirements if they are amended solely to comply with the new regulations restricting certain qualified financial contracts of

December 17, 2018

The Comptroller of the Currency, Federal Reserve Board and FDIC proposal allowing "advanced-approaches" banking organizations (i.e., those with $250 billion or more in total consolidated assets, or $10 billion or more in on-balance sheet foreign exposure) to use an alternative approach for calculating derivative exposures under regulatory capital rules was published in the Federal Register. Comments must be received before February 15, 2019. As previously covered, the proposed approach - the standardized approach for counterparty credit risk ("SA-CCR") - would replace the current exposure

March 19, 2019

U.S. prudential regulators, including the Federal Reserve Board, Office of the Comptroller of the Currency, FDIC, Farm Credit Administration and the Federal Housing Finance Agency issued an interim final rule to create certain Brexit-related swap margin requirement exceptions. The interim final rule was published in the Federal Register (see here for previous coverage). The interim final rule is effective on March 19, 2019. Comments must be submitted to the regulators by April 18, 2019.

February 15, 2019

The Comptroller of the Currency, the Federal Reserve Board and the FDIC extended the comment period on a proposal allowing "advanced-approaches" banking organizations (i.e., those with $250 billion or more in total consolidated assets, or $10 billion or more in on-balance sheet foreign exposure) to use an alternative approach for calculating derivative exposures under regulatory capital rules. The comment period deadline was extended from February 15, 2019 to March 18, 2019.